The Centers for Medicare & Medicare Services (CMS) released the final rule for the annual Medicare Physician Fee Schedule (MPFS) on November 2. The final rule will go into effect on January 1, 2022, on the heels of significant changes made to the 2021 fee schedule a year earlier.
What’s New?
The final rule includes several notable changes, such as the refinement of evaluation and management (E/M) visit codes and the extension of telehealth coverage through 2023. The greatest impact of the 2022 MPFS on provider reimbursement is that CMS has finalized the reduction of the conversion factor to $33.59 for 2022 down from $34.89 in 2021.
The 2021 MPFS included a temporary 3.75% increase to the conversion factor, which mitigated some of the decrease and overall changes finalized in the 2021 MPFS. The conversion factor increase was intended to lessen the projected decrease in reimbursement for many providers and specialties related to COVID-19. The effect of the E/M change in the 2021 MPFS increased RVUs for certain primary care and cognitive specialties while keeping procedural and hospital-based providers RVUs largely flat. Based on the 2022 MPFS, procedural and hospital-based providers may see a larger decline in Medicare reimbursement, and primary care and cognitive specialties increases will be less significant.
What Now?
Your strategy for transitioning to the 2022 MPFS will depend on the compensation model(s) your organization is using. With changes imminent, here’s how your organization can prepare:
- Evaluate your current compensation methodologies for employed and integrated providers to assess the impact related to the change.
- Assess the impact on PSAs and other arrangements that are funded and/or distributed on a compensation per WRVU factor.
- Consider methodological adjustments to ensure financial sustainability at the organizational level and mitigate volatility at the individual provider compensation level.
- Because these changes might also impact the FMV determination of certain arrangements, review and audit your provider arrangements.
Published November 4, 2021